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The ALAC welcomes many of the changes made to the .com contract, particularly those that will enhance security and consumer trust, and has no substantive comment on the proposed changes per se. However, the ALAC expresses extreme disappointment that ICANN has not yet taken this opportunity to require .com to use a Thick WHOIS model, the model that is required for all new gTLDs. This position is strengthened by the GNSO Council's recent decision to defer discussion on actually starting the Thick WHOIS PDP until, December 2012.
 
The Final Issue Report on ‘Thick” WHOIS identified many benefits including enhanced security and stability, and attractive archival and restoration properties in the case of business or technical failure of registrars.  That report acknowledged that privacy may be an issue with a ‘thick’ WHOIS but noted that it has been dealt with in other ways.  The Report, now over two months old, called for a PDP on Thick WHOIS issues raised or, because only Verisign maintains ‘thin’ WHOIS, direct negotiations between ICANN and Verisign.

The ALAC believes that the delay of the PDP runs counter to the global public interest in having the this important issue dealt with as quickly as possible. We urge ICANN and Verisign not to wait for the PDP in order to address this as an implementation matter, and to include a requirement for a Thick WHOIS in the current contract revision. This would efficiently provide all .com registrants with the benefits that ICANN has already stated to be important for any TLD.